Privacy

Responsibility for the processing of personal data:

Better Days
c/o Velychko
Fritschistrasse 5
8003 Zurich
Switzerland

privacy@betterdays.ngo

We will notify the subject if there are other parties responsible for processing personal data in individual cases.

Data protection representation in the European Economic Area (EEA)

We have the following data protection representation in accordance with Art. 27 GDPR:

Better Days Greece
Xanthou 8
81100 Mytilene, Lesvos
Greece

compliance@betterdays.ngo

The Data Protection Representation serves as an additional point of contact for data subjects and authorities in Greece, the European Union (EU), and the rest of the European Economic Area (EEA) for enquiries related to the GDPR.

2.1 Terms

Personal data is any information relating to an identified or identifiable natural person. A data subject is a person about whom we process personal data.

Processing includes any handling of personal data, irrespective of the means and procedures used, such as querying, matching, adapting, archiving, preserving, reading out, disclosing, procuring, recording, collecting, deleting, disclosing, arranging, organising, storing, modifying, disseminating, linking, destroying, and using personal data.

The European Economic Area (EEA) comprises the member states of the European Union (EU) as well as the Principality of Liechtenstein, Iceland, and Norway. 

2.2 Legal basis

We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act (FADP/Datenschutzgesetz, DSG) and the Data Protection Ordinance (DPA/Datenschutzverordnung, DSV).     

We process – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – personal data in accordance with at least one of the following legal bases:

• Art. 6 (1)(b) GDPR for the necessary processing of personal data for the fulfilment of a contract with the data subject as well as for the implementation of pre-contractual measures.
• Art. 6 (1)(f) GDPR for the necessary processing of personal data to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out and communicate about our activities and operations in a permanent, user- friendly, secure, and reliable manner, the guarantee of information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law.
• Art. 6 (1)(c) GDPR for the necessary processing of personal data to comply with a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA).
• Art. 6 (1)(e) GDPR for the necessary processing of personal data for the performance of a task that is in the public interest.
• Art. 6 (1)(a) GDPR for the processing of personal data with the consent of the person concerned.
• Article 6(1)(d) of the GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person.

We process the personal data that are necessary to be able to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. Such personal data may in particular fall into the categories of inventory and contact data, context related information on personal situation, browser and device data, content data, meta or marginal data and usage data, location data, sales data, as well as contract and payment data.

We process personal data for the duration required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required is anonymised or deleted.

We may have personal data processed by third parties. We may process personal data jointly with third parties or transmit it to third parties. Such third parties are, in particular, specialised providers whose services we use and work with. We also guarantee data protection for such third parties, as far as it is within our power.

As a matter of principle, we only process personal data with the consent of the persons concerned. If and insofar as the processing is permitted for other legal reasons, we may waive the requirement to obtain consent. For example, we may process personal data without consent in order to fulfil a contract, to comply with legal obligations, or to protect overriding interests.

In this context, we process in particular information that a data subject voluntarily provides to us when contacting us – for example, by letter, email, application or other online forms and surveys, instant messaging, contact form, social media, or telephone – or when registering for a user account. We may store such information, for example, in an address book, in a cust- omer relationship management system (CRM system) or with comparable tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection with regard to these persons as well as to ensure the accuracy of this personal data.

We also process personal data that we receive from third parties, obtain from publicly available sources, or collect in the course of our activities and operations, if and to the extent that such processing is permitted for legal reasons.

We process personal data about individuals who register for our programmes and services to the extent necessary to assess their eligibility for participation, analyse their individual needs and provide them with relevant services and support as well as monitoring and evaluate our activities. The type of personal data requested and processed depends on the programme or service in question. Upon application, we inform individuals about the processing of their personal data in the respective context.

We may use the stories, pictures and video recordings of participants in our programmes as part of our advocacy, communication and fundraising activities, but we do so only after obtaining the explicit consent from the individuals concerned. 

We process personal data about applicants to the extent that it is required for assessing their suitability for an employment relationship or for the subsequent performance of an employment contract. The necessary personal data results in particular from the information requested, for example in the context of a job advertisement. We also process the personal data that applicants voluntarily provide or make public, in particular as part of cover letters, CVs, and other application documents, as well as online profiles.

We process – if and insofar as the General Data Protection Regulation (GDPR) is applicable – personal data about applicants in particular in accordance with Art. 9 (2)(b) GDPR.

We may allow applicants to enter their details into our talent pool so that they can be considered for future vacancies. We may also use such information to maintain contact and provide updates. If we believe that an applicant is eligible for a vacancy based on the information provided, we may inform the applicant accordingly.

We process personal data in Switzerland and in the European Economic Area (EEA), in particular in Greece. However, we may also export or transfer personal data to other countries in order to process it or have it processed there.

We may export personal data to all states and territories on earth as well as elsewhere in the universe, provided that the law there ensures adequate data protection in accordance with the decision of the Swiss Federal Council and – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – in accordance with the decision of the European Commission.

We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. In exceptional cases, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, for example the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or a copy of any guarantees on request.

7.1 Data protection claims

We grant data subjects all rights in accordance with the applicable data protection law. In particular, data subjects have the following rights:

• Information: Data subjects may request information as to whether we are processing personal data about them and, if so, what personal data is involved. Data subjects can obtain the information necessary to assert their data protection rights and to ensure transparency. This includes the personal data processed as such, but also, among other things, information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data.

• Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted.

• Deletion and objection: Data subjects can have personal data deleted (“right to be forgotten”) and object to the processing of their data with effect for the future.

• Data release and data transfer: Data subjects may request the surrender of personal data or the transfer of their data to another data controller.

We may suspend, restrict, or refuse the exercise of the rights of data subjects to the extent permitted by law. We can draw the attention of data subjects to any requirements that must be met in order to exercise their rights under data protection law. For example, we may refuse to provide information in whole or in part with reference to confidential information or the protection of other persons. We may also, for example, refuse to delete personal data in whole or in part with reference to statutory retention obligations.

We may occasionally impose costs for the exercise of the rights. We will inform affected persons in advance of any costs.

We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate.

7.2 Right to complain

Data subjects have the right to enforce their data protection rights by legal means or to lodge a complaint with a competent data protection supervisory authority.

The data protection supervisory authority for private data controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC, Eidgenössische Datenschutz- und Öffentlichkeitsbeauftragte, EDÖB).

The data protection supervisory authority for private data controllers and federal bodies in Greece is the Hellenic Data Protection Authority.

Data subjects have the right – if and to the extent that the General Data Protection Regulation (GDPR) is applicable – to lodge a complaint with a competent European data protection supervisory authority.

We take suitable technical and organisational measures to ensure data security appropriate to the respective risk. However, we cannot guarantee absolute data security.

Access to our website is via transport encryption (SSL/TLS, particularly with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers indicate transport encryption with a padlock in the address bar.

Our digital communication – in principle all digital communication – is subject to mass surveillance without cause or suspicion and other surveillance by security authorities in Switzerland, Greece, the rest of Europe, the United States of America (USA), and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police agencies, and other security authorities.

9.1 Cookies

We may use cookies – our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies). Cookies are data that are stored in the browser. Such stored data need not be limited to traditional cookies in text form.

Cookies can be stored in the browser temporarily as “session cookies” or for a certain period of time as so-called permanent cookies. Session cookies are deleted automatically when the browser is closed. Permanent cookies have a certain storage period. Cookies make it possible in particular to recognise a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used, for example, for online branding.

Cookies can be completely or partially deactivated and deleted in the browser settings at any time. Without cookies, our website may no longer be fully available. We actively request your express consent to the use of cookies, at least to the extent necessary.

In the case of cookies used for performance and reach measurement or for advertising, a general objection (“opt-out”) is possible for numerous services via AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAd- Choices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA).

9.2 Server log files

We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website called up including amount of data transferred, website last called up in the same browser window (referer or referrer).

We store such information, which may also constitute personal data, in server log files. The information is required to provide our website in a permanent, user-friendly, and reliable manner and to ensure data security and thus in particular the protection of personal data – also by third parties or with the help of third parties.

9.3 Tracking pixel

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels – also from third parties whose services we use – are small, usually invisible images that are automatically retrieved when you visit our website. With pixel counters, the same information can be collected as in server log files.

We may send notifications and messages via email and other communication channels such as instant messaging or SMS.

10.1 Success and reach measurement

Notifications and messages may contain web links or tracking pixels that record whether an individual message was opened and which web links were clicked. Such web links and tracking pixels may also record the use of notifications and messages on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages effectively and in a user-friendly manner based on the needs and reading habits of the recipients.

10.2 Consent and objection

Principly, you must expressly consent to the use of your e-mail address and other contact addresses, unless the use is permitted for other legal reasons. If possible, we will use the “double opt-in” procedure for any consent, i.e. you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorised third parties can take place. We may log such consents, including the IP address, date and time, for reference and security reasons.

Principly, you can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement. This is subject to any notifications and communications required in connection with our activities and operations.

10.3 Service provider for notifications and messages

We send notifications and messages with the help of specialised service providers.

We use in particular:

• Mailchimp: communication platform; provider: The Rocket Science Group LLC DBA Mailchimp (USA) as a subsidiary of Intuit Inc. (USA); information on data protection: privacy policy (Intuit) including “Country and Region-Specific Terms”, “Frequently Asked Questions about Data Protection at Mailchimp“, “Mailchimp and European Data Transfers“, ” Security“, Cookie Policy, “Privacy Rights Requests“, “Legal Provisions“.

We are present on social media platforms and other online platforms in order to communicate with interested persons and to inform them about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland and the European Economic Area (EEA).

The General Terms and Conditions (GTC) and terms of use, as well as data protection declarations and other provisions of the individual operators of such platforms, also apply in each case. These provisions are particularly informative about the rights of affected persons directly via the respective platform, which includes, for example, the right to information.

We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called page insights, insofar as and to the extent that the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page insights provide information about how visitors interact with our Facebook presence. We use page insights to ensure our presence on Facebook is effective and user-friendly.

Further information on the type, scope, and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook, as well as Facebook’s data protection officer, can be found in Facebook’s privacy policy. We have entered into the so-called “Controller’s Addendum” with Facebook and have thus agreed in particular that Facebook is responsible for ensuring the rights of data subjects. For page insights, the corresponding information can be found on the page “Information on page insights” including “Information on page insights data“.

We  may use the services of specialised third parties in order to carry out our activities and operations in a permanent, user-friendly, secure, and reliable manner. With such services we can, among other things, embed functions and content into our website. In the case of such embedding, the services used record the IP addresses of the users at least temporarily for technically compelling reasons.

For necessary security-related, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymised, or pseudonymised form. This is, for example, performance or usage data in order to be able to offer the respective service. We use in particular:

• Google services: Provider: Google LLC (USA)/Google Ireland Limited (Ireland) for users in the European Economic Area (EEA) and Switzerland; General information on data protection: “Privacy and security principles“, data protection statement, “Google is committed to complying with applicable data protection laws“, “Guide to data protection in Google products“, “How we use data from websites or apps on or in which our services are used” (information from Google), “Types of cookies and other technologies used by Google“, “Personalised advertising” (activation / deactivation / settings) (Google’s disclosures).

12.1 Digital infrastructure

We use the services of specialised third parties to provide the digital infrastructure required in connection with our activities and operations. These include, for example, hosting and storage services from selected providers. We use in particular:

• Google Cloud including Google Cloud Platform (GCP): storage and other infrastructure; Google Cloud-specific providers: Google/ LLC (USA) for users in the USA / Google Ireland Limited or Google Commerce Li- mited (both Ireland) for users in the European Economic Area (EEA) and Switzerland (see “Google Contracting Entity” for the providers in other countries); Google Cloud specific information: “Privacy Resource Centre“, “Data Protection“, “Compliance Resource Centre“, “Trust and Security“.

• Gigaquad and Hetzner: The website is hosted by Gigaquad (the company does not process any personal data generated by the website) and the server is run by: Hetzner Online GmbH / Hetzner Cloud GmbH (Falkenstein, Germany); Data protection information: “Privacy policy“, “Data Protection FAQ“.
• WordPress.com: Blog hosting and website builder; Provider: Automattic Inc. (USA)/Aut O’Mattic A8C Ireland Ltd. (Ireland) for users in Europe, among others; data protection information: “privacy policy“, “cookie policy“.

12.2 Contact options

We may use services from selected providers to better communicate with third parties such as potential and existing supporters. We may use in particular:

• Salesforce: Customer Relationship Management (CRM); Provider: Salesforce.com Inc. (USA)/Salesforce.com Germany GmbH (Germany); Data protection information: “Privacy“.

12.3 Scheduling

We use the services of specialised third parties to make appointments online, for example for meetings. In addition to this data protection declaration, any directly visible conditions of the services used, such as terms of use or data protection declarations, also apply. We use in particular:

• Google Calendar: Online scheduling; Provider: Google; Google Calendar-specific information: “Scheduling with Google Calendar“, “Privacy in Google Calendar“.
• Doodle: Online appointment scheduling; Provider: Doodle AG (Switzerland) as a subsidiary of TX Group AG (Switzerland); Data protection information: Data protection declaration, “General Terms and Conditions of the Processing of Personal Data».

12.4 Audio and video conferences

We use specialised audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services, such as data protection declarations and terms of use, also apply.

Depending on the situation, we recommend muting the microphone by default when participating in audio or video conferences, as well as blurring the background or having a virtual background superimposed. We use in particular:

• Google Meet: video conferencing; provider: Google; Google Meet specific information: “Google Meet – Security and Privacy for Users“.
• Slack: Productivity platform; provider: Slack Technologies Limited (Ireland), Slack Technologies Incorporated (USA), a Salesforce, Inc. (USA) company; Data protection information: “Privacy Policy“.

12.5 Online collaboration

We use the services of third parties to enable online collaboration. We use in particular:

• Slack: Productivity platform; provider: Slack Technologies Limited (Ireland), Slack Technologies Incorporated (USA), a Salesforce, Inc. (USA) company; Data protection information: “Privacy Policy“.

12.6 Social media functions and social media content

We can use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways. We can use in particular:

• Facebook (social plugins): Embedding of Facebook functions and Facebook content, for example “Like” or “Share”; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: data protection declaration.
• Instagram platform: Embedding of Instagram content; Provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); information on data protection: “data protection declaration (Instagram)“, “data protection declaration (Facebook)“.
• LinkedIn Consumer Solutions Platform: Embedding of functions and content from LinkedIn, for example with plugins such as the “Share Plugin“; Provider: Microsoft; LinkedIn-specific information: “Privacy Policy“, “Cookie Policy“.

12.7 Map material

We use third party services to embed maps on our website. In particular, we use:

• Google Maps: mapping service; provider: Google; Google Maps-specific information: “How Google uses location information“.

12.8 Digital audio and video content

We use services from specialised third parties to enable the direct playback of digital audio and video content such as music or podcasts. We use in particular:

• YouTube: Video platform; Provider: Google; YouTube-specific information: “Data protection and security centre“, “My data on YouTube“.

12.9 Documents

We use third party services to integrate documents into our website. Such documents may include, for example, forms, PDF files, presentations, tables, and text documents. This enables us not only to view, but also to edit or comment on such documents. We use in particular:

• Canva Docs: Digital Documents; Provider: Canva Pty Ltd (Australia); Privacy Disclosures:
  “Privacy Policy“, “Trust“, “Security at Canva“, “Cookie Policy“, “Legal“.
• Google Docs: documents as well as forms, presentations and spreadsheets; provider: Google; Google Docs-specific information: “Privacy in Google Docs, Google Spreadsheets and Google Presentations“.

12.10 Donations and Payments

We may use specialised service providers to process donations and payments securely and reliably. The legal texts of the individual service providers, such as the General Terms and Conditions (GTC) or data protection declarations, also apply to the processing of payments.
We may use in particular:

• GlobalGiving: Fundraising platform; providers: GlobalGiving, a 501(c)(3) organization (EIN: 30‑0108263) Registered Charity in England and Wales # 11228231 Thomas Circle NW, Suite 800, Washington, DC 20005, USA; Data protection information: “Privacy policy“, “Cookie policy“, “GlobalGiving + GDPR“
• PayPal: Processing of payments; providers: PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg) / PayPal Pte. Ltd. (Singapore); Data protection information: “Privacy policy“, “Statement on cookies and tracking technologies“.
• PostFinance: e-payment solutions; provider: PostFinance AG (Switzerland); information on data protection: “Legal information and accessibility“, “Data protection” (including data protection statements)“.
• RaiseNow: Fundraising platform; Provider: RaiseNow AG (Switzerland) / Raise- Now GmbH (Germany); Data protection information: “Data protection declaration“, “Guidelines of cooperation: Fair and sustainable action“, “certification according to Payment Card Industry Data Security Standard (PCI DSS)“.
• Piraeus Bank: bank and e-payment solutions; provider: Piraeus Bank (Greece); Data protection information: «privacy policy»

12.11 Advertising

We can use the option of displaying targeted advertisements for our activities and operations on third parties such as social media platforms and search engines.

With such advertising, we would like to reach in particular people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we can transmit corresponding – possibly also personal – information to third parties who make such advertising possible. We may also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking).

Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our website to your profile there. We can use in particular:

• Facebook Advertising (Facebook Ads): Social media advertising; provider: Meta Platforms Ireland Limited (Ireland) and other Meta companies (including in the USA); data protection information: remarketing and targeting, in particular with the Facebook Pixel and Custom Audiences including Lookalike Audiences, data protection statement, “advertising preferences” (user registration required).
• Google Ads: search engine advertising; provider: Google; Google Ads-specific indicia: Advertising based, inter alia, on search queries, with different domain names – in particular doubleclick.net, googleadservices.com and googlesyndication.com – being used for Google Ads, “Advertising” (Google), “Why do I see a certain ad“?

12.12 Surveys

We may use third party services to to conduct surveys. In particular, we may use:

• SurveyMonkey: Survey platform; provider: SurveyMonkey Europe UC (Ireland); data protection information: “Privacy notice“, “Cookie notice“
• Google Forms: online Form and survey platform; provider: Google; information on data protection: “privacy policy”

We use extensions for our website in order to be able to use additional functions. We use in particular:

• Google reCAPTCHA: Spam protection (differentiation between wanted comments from humans and unwanted comments from bots as well as spam); Provider: Goog- le; Google reCAPTCHA-specific information: “What is reCAPTCHA?“.

We try to determine how our online materials are used. In this context, we can, for example, measure the success and reach of our activities and operations as well as the effect of third-party links to our website. We can also, for example, test and compare how different parts or versions of our online offer are used (“A/B test” method). Based on the results of the performance and reach measurement, we can correct errors, strengthen popular content, or make improvements to our online presence.

In most cases, the IP addresses of individual users are stored for the purpose of measuring success and reach. In this case, IP addresses are always shortened (“IP masking”) in order to follow the principle of data economy through the corresponding pseudonymisation.

Cookies may be used to measure success and reach and user profiles may be created. Any user profiles created include, for example, the individual pages visited or content viewed on our website, information on the size of the screen or browser window, and the approximate location. Principly, any user profiles are created exclusively in pseudonymised form and are not used to identify individual users. Individual services of third parties with which users are registered can, if necessary, allocate the use of our online offer to the user account or user profile with the respective service. We use in particular:

• Google Analytics: performance and reach measurement; provider: Google; Google Analytics-specific data: Measurement also across different browsers and devices (cross- device tracking) and with pseudonymised IP addresses, which are only transmitted in full to Google in the USA in exceptional cases, “Data protection“, “Browser add-on to deactivate Google Analytics“.

We have created this data protection declaration with the data protection generator of Datenschutzpartner, translated it from German into English with DeepL Pro, made several adjustments, and added additional information.

We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current data protection declaration on our website.